Evaluation of grants administration Phase one: Commercial grants

Summary

In the body's own words

1. Finding

   Despite the exposure of these two departments to considerable corruption risks, the Commission was encouraged to find many sound features in the practices, policies and procedures underpinning grants management.

   Report, page 6

Findings, opinions and statements

Allegations are not findings. A commission's finding or opinion of corrupt conduct or misconduct is not a finding that a person is guilty of a criminal offence, and the commissions say so in their reports.

No findings are reproduced in this record. This does not establish that the report contains none.

Recommendations 29

1. Recommendation 1

   DIIS include references to grants management policy and procedure in the Department’s Fraud Control Plan activity table.

   Report, page 8

2. Recommendation 2

   DIIS provide six monthly reminders to staff of their obligations to declare conflicts of interest and relevant pecuniary interests, and of the need to request approval for outside employment.

   Report, page 8

3. Recommendation 3

   Determine an appropriate third party assessment and approval process for acceptance of gifts and benefits by the Chief Executive.

   Report, page 8

4. Recommendation 4

   DIIS prioritise implementation of an appropriate system and its use by all staff working in grants administration, including the rollout of staff training, and guidance on document retention; and review staff use of the system one year from full implementation.

   Report, page 8

5. Recommendation 5

   DIIS conduct a review of assessment documentation related to grants with a view to standardising the process, including requirements for fulsome justification of decisions and recording of all decisions and decision makers.

   Report, page 8

6. Recommendation 6

   Subject to resourcing, DIIS consider the creation of a fully centralised and dedicated grants administration unit.

   Report, page 8

7. Recommendation 7

   DIIS Audit and Risk Committee review its processes for overseeing the implementation of audit recommendations in general, and the BDO audit of grants administration in particular.

   Report, page 8

8. Recommendation 8

   DIIS more clearly define the budgetary parameters and purposes of the RIF, and set out clear conditions where a publicised grant fund may be used for internal procurements, or disallow the use of the fund for anything other than grants.

   Report, page 9

9. Recommendation 9

   DIIS amend all relevant policy and procedure to ensure that any restrictions on open publishing of grants opportunities, or specifically targeted grants calls or invitations, are justified, approved and documented.

   Report, page 9

10. Recommendation 10

    DIIS include the following requirements in the Grants Management Framework: ⊲ Assessment panel meeting minutes consistently record any conflict of interest declarations, including no disclosures, at the commencement of each meeting ⊲ All panel members disclose conflict of interests either via signed paper declaration or electronically, with controls for verification of identity ⊲ Grant application forms to require the applicant to disclose conflicts of interests

    Report, page 9

11. Recommendation 11

    DIIS amend its Conflict of Interest Procedure and Fraud Control Plan to reflect that all DIIS staff with decision making duties involved in grants administration are required to complete a pecuniary interest declaration form annually.

    Report, page 9

12. Recommendation 12

    DIIS implement a ‘flag’ for any grant applicants identified as public officers, and require grant assessors to ascertain whether any conflicts of interest arise in relation to their public duties and activities for which they are seeking grant funding.

    Report, page 9

13. Recommendation 13

    DIIS require employees involved in grants administration to undertake fraud risk training, including conflicts of interest, grooming, gifts and benefits, professional relationships and financial interests, at least every three years.

    Report, page 9

14. Recommendation 14

    DIIS consolidate all RIF recipients and publishes the list on its website.

    Report, page 9

15. Recommendation 15

    DIIS conduct formal and documented periodic reviews of the RIF to ensure that the program remains relevant to strategic policy objectives, delivers intended outcomes, that appropriate processes are followed, and integrity controls are functioning effectively.

    Report, page 10

16. Recommendation 16

    DTI provide periodic training on fraud, corruption and integrity risks relevant to high risk functions conducted by staff at the Department, including grants administration.

    Report, page 10

17. Recommendation 17

    DTI amend the Department’s Gifts and Benefits Register to include a prompt for recipients to provide detailed information of any relevant connection (current or proposed) between an offeror and the Department, such as procurement or grants activity, or other associations.

    Report, page 10

18. Recommendation 18

    DTI issue six monthly reminders to staff regarding their conflict of interest obligations.

    Report, page 10

19. Recommendation 19

    DTI amend its Conflict of Interest Procedure to require all DTI staff with decision making duties in grants administration to complete a pecuniary interest declaration annually.

    Report, page 10

20. Recommendation 20

    DTI create a CRM working group to establish protocols for requesting, using, storing and accessing commercial in confidence information of clients. The working group should assess general information and document security practices in line with State Records requirements and current policy and procedure, with a view to embedding consistent information handling processes at the Department.

    Report, page 10

21. Recommendation 21

    DTI periodically audit staff use of the CRM to identify unusual or suspicious patterns of access, downloading and dissemination. Such system access review should also occur in the lead up to any senior staff exiting the agency to take up positions in the private sector.

    Report, page 10

22. Recommendation 22

    DTI amend its Expense Management – Grants Procedure to stipulate that substantial alteration of a grants program, including changes to scope, purpose or budgets, require an integrity risk assessment before approval.

    Report, page 11

23. Recommendation 23

    DTI ensure complex and multi-stage grants programs have mechanisms in place for the final approver to have global visibility over the key points of conflict of interest management, including expression of interest, eligibility review, assessment, selection, as well as processes involving departmental officers working on business strategy or plans with applicants and recipients.

    Report, page 11

24. Recommendation 24

    DTI gives consideration to the creation of resources to facilitate ethical industry engagement between agency officers and businesses, as well as protecting their own integrity during those engagements.

    Report, page 11

25. Recommendation 25

    DTI ensures that a consistent minimum level of due diligence, business and financial review takes place for all recipients of grants, and documentary evidence is retained in records management systems. It is suggested that the agency consult with the South Australian Government Financing Authority regarding potential provision of due diligence or assurance services, particularly for international applicants or applicants with difficult to ascertain finances or business cases.

    Report, page 11

26. Recommendation 26

    DTI review its grants operating procedures to ensure that changes to roles and responsibilities resulting from restructures and operational adjustments are reflected in those procedures, and all roles listed with any discretionary powers are required to make conflict of interest declarations.

    Report, page 11

27. Recommendation 27

    DTI standardise its grants assessment scoring documents so panel members can be matched to individual scores, and conflict of interest declaration and management actions are attached to the assessment documentation.

    Report, page 11

28. Recommendation 28

    DTI ensure that panel assessment documents for grants programs are attached to approval minutes, to ensure retention of those documents.

    Report, page 12

29. Recommendation 29

    DTI undertake a strategic review of SALP participant progress reports to gather insights for program review and evaluation.

    Report, page 12

Published responses

No published response was found.

Coverage

This publisher

• Office for Public Integrity: publishes only its annual reports (excluded); no OPI report or statement records.
• Since October 2021 the Commission does not make findings of corrupt conduct; most records have no findings.
• Government and agency responses are recorded only where the Commission's page links them or the report reproduces them; implementation status is not published by the Commission as structured data.
• Scanned reports without a text layer are not read (no OCR); their recommendations stay not_extracted.
• Recommendations are extracted only from numbered 'Recommendation N' lists; reports that set out recommendations in prose, tables or unnumbered lists keep recommendations_status not_extracted.
• Findings are extracted only from investigation reports that state them in the Commissioner's own words (Oakden 2018, Gillman 2015); public statements are not read for findings.